Citation: Sultan Singh (Dead) through LRs & Ors. v. The Financial Commissioner, Government of NCT of Delhi & Ors., Civil Appeal No. 9146 of 2012, Supreme Court (Justices S.V.N. Bhatti and N.V. Anjaria), decided on 09.10.2026 | 2026 INSC 1107
The Supreme Court has held that when a Hindu woman who inherited agricultural land in Delhi as a widow or mother dies, the land goes to her own heirs under the Hindu Succession Act, 1956, and not back to her late husband’s male relatives, if the 1956 Act had already made her the full owner before her death.
The land is about 45 bighas in Bhawana village. Khajano was a widow who held the land as a limited owner after the deaths of her husband Mauji Ram and her son Ram Chander, and she was declared a Bhumidhar under the Delhi Land Reforms Act, 1954. She remarried Bal Kishan, and had two sons, Chand Ram and Chander Bhan. After she died in 1973, her sons applied for mutation in 1997, and the Sub-Divisional Magistrate and two higher revenue authorities agreed. Descendants of Mauji Ram’s relatives (the “reversioners”) challenged this, and a Single Judge of the Delhi High Court sided with them in 2004. They argued that Khajano held only a limited estate when the 1954 Act came into force, so the land should return to the male heirs of the last male owner under Section 51(2)(a)(i). A Division Bench reversed this in 2012, and the reversioners appealed. Justices S.V.N. Bhatti and N.V. Anjaria dismissed the appeal. They held that Section 51(2) of the 1954 Act refers to the “personal law applicable to her” in general terms, so it is not frozen at 1954 but means the law in force when she dies. They relied on the Supreme Court’s three-judge ruling in Bajaya, and on the words in the section, “dies”, in the present tense, as showing that the date of death matters. Since Section 14(1) of the Hindu Succession Act, 1956 turned a Hindu woman’s limited estate into full ownership, Khajano held the land absolutely when she died in 1973, so succession falls under Section 51(2)(a)(ii) and Section 53, which favours her own heirs. The court also held that the 1954 Act is a complete code for such land, but that it incorporates the personal law in this way, and it distinguished the cases cited by the reversioners as not directly on point.